摘要：Despite the growing need for private sector participation (PSP) in the water sector, private sector investments in the water sector have experienced a downturn in recent years, especially concession projects, which accounted for nearly 80 percent of all PSP projects in urban water utilities from 1990 to 2005. This paper traces the concession to its origin—the French model—and focuses on the challenges of transferring the model into the context of developing countries, by comparing two cases of concession projects in Jakarta and Manila. This comparative analysis suggests that although the French model appears a compelling choice because of its promise of attracting capital investments and improving efficiency, successful applications of the model may require substantial modifications to its original form in order to adapt to prevailing legal and social norms as well as to local governance capacity.
